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Guidance Released on COLI Best Practice Rules
4) is issued or “materially changed” after Aug. 17, 2006. An applicable policyholder is a person who ... rules apply only to contracts “issued” after Aug. 17, 2006, and because the notice and con- sent requirements ...- Authors: Application Administrator, Bryan W Keene, Joel Winston Mann
- Date: Sep 2009
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Life Insurance; Public Policy
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IRS Notice Helps Government Money Market Funds Satisfy Diversification Rules
12. See also Webber v. Commissioner, 144 T.C. No. 17 (June 30, 2015); Christoff ersen v. United States ... 468. See also Webber v. Commissioner, 144 T.C. No. 17 (June 30, 2015). 8 “Insurance-dedicated” means that ...- Authors: John Adney, Bryan W Keene
- Date: Oct 2016
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting
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Planning Ahead: Revenue Procedure Could Help Separate Accounts Comply with Section 817(h) When Investing in a New Type of Mortgage-Backed Securities
under that contract. FEBRUARY 2019 TAXING TIMES | 17 DETAIL ON THE NEW GUIDANCE Let’s look further at ... deemed to be issued by Fannie Mae and Freddie Mac;17 this ratio continues to apply thereafter to all ...- Authors: John Adney, Bryan W Keene
- Date: Mar 2019
- Competency: Technical Skills & Analytical Problem Solving
- Publication Name: Taxing Times
- Topics: Finance & Investments; Pensions & Retirement
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IRS Rules on New BOLI Arrangement
generally applies to contracts issued after Aug. 17, 2006, subject to certain transition rules. Under ... does not apply to: a contract issued after [Aug. 17, 2006] pursuant to an ex- change described in section ...- Authors: John Adney, Bryan W Keene
- Date: May 2012
- Competency: External Forces & Industry Knowledge>External forces and business performance
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting
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Product Tax Seminar and Optional Boot Camp Presentations
business, or financial relationship with the insured. 17 Life Settlement Reporting (cont.) • Issuer re ... general reporting requirement for IRAs 14 Rev. Rul. 2018‐17 • Facts • Individual is a U.S. person and has a ...- Authors: John Adney, Rebecca Baxter, Art Dunlavy, Philip Ferrari, Robert A Fishbein, Sheryl Flum, John Glover, Mark Griffin, Lawrence Hersh, Kay Hossofsky, Samera Kadry, Bryan W Keene, Brian King, Eric Lanning, Kimberly W Lunn, Casey Malone, Kristin R Norberg, Mandana Parsazad, Alison R Peak, Daniel Phillips, Craig R Springfield, Jeffrey Stabach, Daniela Stoia
- Date: Sep 2018
- Competency: External Forces & Industry Knowledge; Technical Skills & Analytical Problem Solving
- Topics: Annuities; Financial Reporting & Accounting; Life Insurance
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The Demise of Sections 809 and 815
REVIEW 31 (January 2001). MAY 2006 327 industry.17 Moreover, the enactment of the Gramm- Leach-Bliley ... Will Congress turn to these provisions next? 3 17 In 2003, stock life insurance companies held approximately ...- Authors: William B Harman, Douglas N Hertz, Bryan W Keene
- Date: May 2006
- Competency: External Forces & Industry Knowledge>External forces and business performance
- Publication Name: Taxing Times
- Topics: Life Insurance; Public Policy
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Why Do Limitations Apply to Owners of Life Insurance Contracts, Particularly COLI?
payment of a substantial number of future premiums.17 This definition presents interpretative questions ... applies to life insurance contracts issued after Aug. 17, 2006, except for a contract issued after that date ...- Authors: Bryan W Keene, Mark Smith
- Date: Jun 2019
- Competency: External Forces & Industry Knowledge; Technical Skills & Analytical Problem Solving
- Publication Name: Taxing Times
- Topics: Life Insurance; Public Policy
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New IRS Letter Ruling Provides Guidance on Substantially Equal Periodic Payments from Immediate Variable Annuities
presented. The Service responded by affirming the ruling.17 However, logic and reason ultimately prevailed on ... amount. : New IRS Letter Ruling ... from pg. 17 18 4TAXING TIMES payments based on interest rate ...- Authors: Application Administrator, Bryan W Keene, Alison L Reynolds
- Date: Sep 2008
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Annuities>Payout annuities
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T3: TAXING TIMES Tidbits
deductible. In a private letter ruling issued on July 17, 2009, and released to the public on November 6— ... TAM 200448046 (Aug. 30, 2004). 5 TAM 8111079 (Dec. 17, 1980). 6 Rev. Rul. 67-435, 1967-2 C.B. 232. Janel ...- Authors: Application Administrator, Charles J Auer, Craig Pichette, Bryan W Keene, Peter Winslow, Janel C Frank, Gregory K Oyler, Michael Edward Bauer
- Date: Feb 2010
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting
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Rev. Proc. 2008-41—Correction of Inadvertent Diversification Failures
is limited to inadvertent diversification errors.17 In the authors’ experience, establishing inadvertence ... Id. at 41,652. 16 T.D. 9385, 2008-15 I.R.B. 735. 17 Treas. Reg. § 1.817-5(a)(2)(i) and Rev. Proc. 2008-41 ...- Authors: Bryan W Keene, Joseph F McKeever
- Date: Feb 2009
- Competency: External Forces & Industry Knowledge; Technical Skills & Analytical Problem Solving
- Publication Name: Taxing Times
- Topics: Annuities>Variable annuities; Life Insurance; Public Policy